OFAC Issues General License 134 Authorizing Temporary Wind-Down For Certain Russian Oil Cargoes
On March 12, 2026, the Office of Foreign Assets Control (OFAC) issued General License 134 (“GL 134”), creating a narrow authorization for the sale, delivery, and offloading of Russian-origin crude oil and petroleum products that were already loaded onto vessels on or before 12:01 a.m. EDT, March 12, 2026. This authorization remains in effect only until 12:01 a.m. EDT, April 11, 2026.
The issuance of GL 134 comes during a period of heightened global energy volatility, with reports noting significant price pressure following intensified conflict involving Iran. Following news reports, those events have contributed to sharply rising oil prices and concerns about supply constraints. See What to Know About the Rising Price of Oil and Its Effects on Airline Ticket Prices – The New York Times.
Scope of Authorized Activities
GL 134 authorizes all transactions ordinarily incident and necessary to the sale, delivery, or offloading of qualifying Russian-origin oil and petroleum products. This includes a wide scope of maritime operational activity that is essential to safely moving oil shipments through global ports and waterways. Following the license terms, authorized activities extend to safe docking and anchoring, the provision of services required for the health and safety of the crew, emergency repairs, and any environmental mitigation or protective operations related to the vessel.
The license further encompasses vessel management and commercial maritime services such as crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. In Note 1 within the license, OFAC expressly states that these activities are authorized even when the relevant vessels themselves are considered “blocked” under one or more of the sanctions authorities referenced in the license.
Russian-Origin Crude Oil and Petroleum Products Covered
Russian-origin crude oil and petroleum products covered by the license also include those produced by entities sanctioned under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587) or Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589). Taken together, these provisions create a narrowly focused but functional pathway for energy traders, refiners, maritime operators, and insurers to complete transactions that were already in progress before March 12.
Original Article: OFAC Issues General License 134 Authorizing Temporary Wind‑Down For Certain Russian Oil Cargoes — Mondaq